ML20151B781

Proposed Tech Specs,Reducing Onsite Nuclear Safety Group Min Staffing Requirement

ML20151B781
Person / Time
Site:	LaSalle
Issue date:	07/12/1988
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML20151B780	List: ML20151B776 ML20151B781
References
NUDOCS 8807210100
Download: ML20151B781 (10)

Text

~ 4 .A J_ .,_r.F, l -

h-o ,

t

'h, e

ATTACMGItT A TECHNICAL SPECIFICAITON CHANGE REOUEST LASALLE COUNTY STATION UNITS 1 AND 2 ERQPOS*D CHANGES TO APPENDIX &

' l REVISED PAGES:

NPF-11 NPF-18 6-2 6-2 I

O$73 PDC 4893K

I ADMINISTRATIVE CONTROLS _ _ , , _ _ , _ _ _ _ _ _________, __

5. The Onsite Nuclear Safety Group (0NSG) shall function to examine unit operating characteristics, NRC isruances, industry acvisories, licensee Event Reports and other sources of plant design and operat-ing experience information, including plants of similar design, which may indicate areas r improving unit safety. The ONSG shall "He composed of at least fou , dedicated, full-time engineers of f multi-disciplines located on site and shall be augmented on a part-4}vree time basis by personnel from other parts of the Commonwealth Edison Company organization to provide expertise not represented in the group. The0NSGshallberesponsible.formaintaininggurveillance of unit activities to provide independent verification tnat these activities are performed correctly and that human errors are reduced as much as practical. The ONSG shall make detailed recommendations for revised procedures, equipment modifications, maintenance activi-ties, operations activities or other means of improving unit safety to the Director, Nuclear Safety.

6. The Station Control Room Engineer (SCRE) serves as the lead control room SR0 during normal operations and as the Shift Technical Adv.isor.

(STA) during abnormal operating and accident conditions. In the event of abnormal operating or accident conditions, the SCRE will relinquish his job as control room SRO to the Shift Foreman ana will assume the role of'STA, when he shall provide technical support to the Shift Supervisor in the areas of thermal hydraulics, reactor engineering and plant analysis with regard to the safe operation of the unit. ,,,

7. Administrative procedures shall be developed and implemented to limit the working hours of unit staff who perform safety-related functions; e q, senior redctor operators, reactor operators, health physicists, auxiliary operators, and key maintenance personnel.

Adequate shift coverage shall be maintained without routine heavy use of overtime. However, in the event that unforeseen problems require substantial amounts of overtime to-be used, the following

• guidelines shall be followed:

a. An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight, excluoing shif t turnover time.

b. An individual should not be permitted to work more inan 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24-hour period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any seven day period, all excluding shift turnover time.

c. A break of at least eight hours should be al3cwed tet.een work periods, including shift turnover time.

d. The use of overtime should be considered on an individual basis and not for the entire staff on a shift.

u Not responsible for sign-off feature.

LA SALLE - UNil 1 6-2

r ADMINISTRATIVE CONTROLS

5. The Onsite Nuclear Safety Group (ONSG) shall function to examine unit operating characteristics, NRC issuances, industry advisories, Licensee Event Reports and other sources of plant design and operat-ing experience information, including plants of similar design, which may indicate areas f_or improving uni 4 safety. The ONSG shall I

( De composed of at least(fou),

f dedicated, full-time engineers of multi-disciplines located on site and shall be augmented on a part-gg time basis by personnel from other parts of the Commonwealth Edison -

Company organization to provide expertise not represented in the group. The ONSG shall be responsible for maintaining gurveillance of unit activi. ties to provide independent verification that these activities are performed correctly and that human errors are reduced as much as practical. The ONSG shall make detailed recommendations for revised procedures, equipment modifications, maintenance activi-ties, operations activities or other means of improving unit safety to the Director, Nuclear Safety.

6. The Station Control Room Engineer (SCRE) serves as the lead control room SRO during normal operations and as the Shif t Technical Advisor (STA) during abnormal operating and accident conditions. In the event of abnormal operating or accident conditions, the SCRE will relinquish his job as control room SR0 to the Shift Fore, man and will  ;

assume the role of STA, when he shall provide technical support to the Shift Supervisor in the areas of thermal hydraulics, reactor engineering and plant analysis with regard to the safe operation of {

the unit.  ;

7. Administrative procedures shall be developed and implemented to limit the working hours of unit staff who perform safety-related functions; e.g, senior reactor operators, reactor operators, health physicists, auxiliary operators, and key maintenance personnel.

Adequate shift coverage shall be maintained without routine heavy use of overtime. However, in the event that unforeseen problems require substantial amounts of overtime to be used, the following guidelines shall be-followed:

a. An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> i straight, excluding shift turnover time.  !

1

b. An individual should not be permitted to work more than '

16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24-hour period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any seven day period, all excluding shift turnover time.

c. A break of at least-eight hours 'should be allowed between work periods, including shift turnover time,

d. The use of overtime should be considered on an individual basis and not for the entire staff on a shift.

Not responsible for sign-off feature.

LA SALLE - UNIT 2 6-2

~

ATTACIBENT B TECHNICAL SPECIFICATION CHANGE REOUEST LASALLE COUNTY STATION UNITS 1 AND 2 BACKGROUND AND DISCUSSICH Following the accident at Three Mile Island Unit 2, the NRC Staff developed the Action Plan, NUREG-0660, to provide a comprehensive and integrated plan to improve safety at power reactors. In November, 1980 a set of THI related actions from NUREG-0660, which were approved for implementation by the Commission, were published in the document NUREG-0737. Included in this NUREG was Item I.B.I.2 - Independent Safety Engineering Group (ISEG).

Under the heading of "Position", the following requirements for the ISEG were provided:

"The principal function of the ISEG is to examine plant operating characteristics, NRC issuances, Licensing Information Service advisories, and other appropriate sources of plant design and operating experience information that may indicate areas for improving plant safety. The ISEG is to perform independent review and audits of plant activities including maintenance, modifications, operational problems, and operational analysis and aid in the establishment of programmatic requirements for plant activities."

"Another function of the ISEG is to maintain surveillance of plant operations and maintenance activities to provide independent verification that these activities are performed correctly and that human errors are reduced as far as practicable. ISEG will then be in a position to advise utility manage-  !

ment on the overall quality and safety of operations." ,

I In NUREG-0800 Item II.3.6., it is further stated that "That group  ;

shall be comprised of a minimum of five dedicated, full-time engineers, l located onsite, but reporting offsite to a corporate official who holds a l high-level, technically oriented position who is not in the management chain I for power productie- 'or utilities with multiple sitea, it may be possible l to perform portions or the independent safety assessment function in a l centralized location for all the utility's plants. In such cases, on Onsite. j Group still is required, but it may be slightly smaller than would be the case l if it were performing the entire independent safety assessment."

The requirement for establishing an ISEG was applied only to applicants for operating licenses. Therefore, LaSalle County Station was the first Edison station to have an ISEG followed closely by Byron and Braidwood.

The size of the ISEG at each of these three stations consists of four full-time engineers. These groups are administered by the Manager of Nuclear Safety who is located in the Company corporate offices. The Manager of Nuclear Safety reports directly to the Chairman and Chief Executive Officer.

Three stations, Zion, Dresden and Quad-Cities, do not have an ISEG.

i

i

. l l

l 1

Commonwealth Edison's nuclear program is large; there are six, two-unit nuclear stations. The completion of Braidwood Unit 2 marks the end of the construction program in the nuclear division. In June of 1987, there was a major reorganization of the nuclear operations area at the corporate level. Also, a Strateo!c Plan for Excellence in Nuclear Operations was created to integrate the goals and action plans of all departments within the Nuclear Operations area to achieve excellence. To achieve the goals of the Strategic Plan, the reorganization had to embody strong central control and direction at the corporate level.

The new organization includes two major station support groups: The first is Licensing and Plant Support Services and the second is Trainir.g, Fuel and Administrative Services. These two groups are each headed by Assistant Vice Presidents who report directly to the Senior Vice President and are independent of plant operations. Some of the responsibilities and functions of those two groups now duplicate the efforts of the ISEG. The new corporate support groups interface with six stations, whereas the ISEG only covers thrt stations. The Licensing and Plant Support Services Group (LPSSG) now has responsibility for performance assessment of the six stations. They monitor station performance utilizing data trending and assessing work procedures and work practices. Among other things, they assess appropriateness of station programs in meeting regulations, standards and guidelines. In addition, they apprise station and corporate management of performance problems including identification of underlying causes and timely resolution to problems.

Another function of the LPSSG is the implementation of the Operation Experience Assessment Program which includes the coordinated development of corrective actions which are uniform across the six stations.

At the station level, the Onsite Regulatory Assurance Department is under the functional control of the Nuclear Licensing Department which is in the LPSSG. This control provides consistency in the review of NRC licensing, inspection and enforceinent correspondence, the tracking of commitments and evaluation of NRC policies and regulations and their impact on the operating stations.

Another department that impacts on the functions of ISEG is the operational section of the Onsite Quality Assurance Group. Like the Department of Nuclear Safety, the Quality Assurance Department is entirely independent of the Nuclear Operations area. The operational section of the Onsite Quality Assurance Group at each of the six stations has one to two people licensed at the SRO level. With their knowledge of plant systems and the technical specifications they are able to perform a knowledgeable independent review and assessment of plant operations.

Since the ISEG is part of the technical specifications, the Quality Assurance Department conducts periodic audits of the ISEG to determine if they are in compliance with the requirements of the applicable section of the technical specifications.

The technical specification required functions of the ISEG are not changed by this proposed amendment. Those review items listed in Technical Specification 6.2.3.1 will continue to be reviewed by the ISEG, however, the ISEG will make further use of the corporate level independent review work in performing onsite reviews.

Based on the above information, it has been concluded the that ISEG size could be reduced from four to three people without any loss.in meeting the requirements of the technical specifications. Using the material developed by all these other support groups in the Nuclear Operations area as a base, the ISEG can perform their functions in a more effective manner with a  ;

lower investment in manhours, and hence fewer people. The option for a lower number of personnel is permitted under N'JREG-0800.

4893K

4 ,

ATTACIBENT C .,

I TECHNICAL SPECIllCATI M C.HANGE LEQUERT MSALLE COUNTY STATIN UNITS 1 AND 2 '

SUPPLEMENTAL INFORMATION The Department of Nuclear Safety is organised.na follows. Heading

~

the department is the Manager of Nuc3sar Safety, who reports directly to 'the Chairman of Commonwealth Edison. Therefore, this department is completely independent of the production area of the Company. Reporting to the Manager.

of Nuclear Safety are the Superintendent of Offsite Review and Investigative Function and the Superintendent'of Safety Engineering.

The Superintendent of the Offsite Review and Investigative Function-fills the requirement of the technical specifications concerning the offcite review function for the six operating stations. Personnel in this offsite-review group are located in the corporate offices. The organisation of the offsite review committee for each of the nuclear stations has a senior participant acting as chairman who directs the review of the appropriate subject matter, supplemented by other Edison or non-Edison personnel, to meet' specific areas of expertise needed for the review.

The Superintendent of Safety Engineering is responsible for the Onsite Nuclear Safety Group (ONSG) at Byron, Braidwood and LaSalle, and a two-man Safety Engineering Support Group at the corporate offices _(refer to attached chart). Each ONSG is headed by a site supervisor who is responsible l for the functioning of his group. The function of the Safety Engineering  !

! Support Group is to assist the ONSG by supplementing the manpower requirements during special safety studies and to act as liaison between the ONSG and other Edison departments to obtain information necessary for the, work performed by-the ONSG. Although we believe the proposed reduction in the staffing of the ONSG at Byron will not create a manpower shortage for the required duties of this group, the corporate Safety Engineering Support Group will be available whenever needed to augment the ONSG. I Attachment B of reference (a) d!scussed the major reorganisation of Commonwealth Edison's nuclear division in June, 1987. The position of Senior Vice President of Nuclear Operations was created, reporting to the Presidenc of Commonwealth Edison. Reporting to the Senior Vice President is a Vice President for PWR operations, a Vice President for BWR operations, an Assistant Vice President for Training, Nuclear Fuel and Administrative Services, and an Assistant Vice President for Licensing and Plant Support Services Group (LPSSG).

- _ - - ~, ~. , _ . _ _ _ . . _ _ _ . -_. .

l i

1 l

The reporting and responsibility of the LPSSG in the nuclear division is structured to provide independence from the two operations Vice Presidents. j The charter of the LPSSG requires that they monitor station performance, conduct technical activities assessments, coordinate off-normal performance event investigations, implement regulatory performance improvement programs, trend regulatory performance parameters, and assure that the operating experience from within and outside Commonwealth Edison is assessed and lessons learned are factored into the Company's plant operations. The functions of the LPSSG cover all six Edison stations. Personnel performing the regulatory assurance duties related to the LPSSG are located both at each nuclear station and at the corporate offices. Personnel in the corporate offices interface with each of the six stations and other Commonwealth Edison departments in the performance of their work.

The LPSSG operation has had the biggest impact on the functions of the ONSG. As the LPSSG developed their procedures and reports over the past year, it became apparent that there was a great deal of overlap on reporting l between the ONSG and the various sections within the LPSSG. The Department of Nuclear Safety and LPSSG are in the process of reviewing the whole area of ,

data gathering, types of reports generated and how the reports are to be used )

by the stations. I 1

The Onsite Quality Assurance Groups, which are independent of the production function, perform audits and surveillances of various station activities. The data and reports which are generated from their audits and surveillances are used by the ONSG to detect possible safety issues. The Qaality Assurance Department is also able to assemble a great deal of histori-cal information on an area under study from past audits and surveillances.

This information is also available to the ONSG.

The duplication of effort and overlapping reviews between the ONSG, LPSSG, and Quality Assurance Department are the bases for the reduction in size of the ONSG. The purpose of the ONSG is to take a stand-back, dispas-sionate look at the area of nuclear safety in plant operations and make recommendations for improvements. This mission can be accomplished more efficiently by making use of the data and reports generated by the LPSSG and Quality Assurance Department.

In summary, Commonwealth Edison believes the proposed reduction in staffing the Byron ONSG will not diminish the group's ability to perform its independent safety assessment function. The corporate Safety Engineering Support Group is available to augment the ONSG when needed. Additionally, Commonwealth Edison has strengthened the overview and assessment areas of nuclear plant operations in the past year. The Department of Nuclear Safety, Quality Assurance Department and LPSSG have developed a close working relationship and, yet, are not comprising their need for independent action.

This working relationship is largely through the sharing of basic data used in the development of each of the three departments' reports. This in turn will permit the most ef ficient and optimal use of manpower in each department.

4893K

ATTACBENT D TECHNICAL SPECIFICATION CHANGE REOUEST LASALLE COUNTY STATION UNITS 1 AND 2 EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION Commonwealth Edison has evaluated this proposed snendment and determined that it involves no significant hazards consideration. According to 10 CFR 50.92(c), a proposed snendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the amendment would nott

1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or

2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or

3) Involve a sigrlficant reduction in a margin of safety.

The purpose of this snendment is to reduce the Onsite Nuclear Safety Group minimum staffing requirement from four engineers to three engineers.

The proposed amendment will have no effect on the consequences of an accident previously evaluated because it will not involve'any physical change in the plant or operating procedures. The proposed snendment may have some ef fect on the probability of an accident previously t: valuated since there will be fewer people performing the independent safety assessment function within the Onsite Nuclear Safety Group (ONSG). However, any increase in this probability will not be significant and will be compensated for by the activities of several new corporate level groups (created by recent corporate organization changes) that are independent of the immediate management chain for power production.

These groups now perform independent assessments of operating characteristics and safety issues that are often redundant to the technical specification responsibilities of the ONSG. This proposed snendment does not change ONSG areas of review as described in the technical specifications. The ONSG retains responsibility for review of those items listed in Technical Specification 6.2.3.1, but will make additional use of the independent review work done by the above noted corporate level groups.

There will be no change in the physical plant or in the way the plant is operated. No new accidents are postulated. As a result, operation of the plant in accordance with the proposed snendment will not create the possibility of a new or different kind of accident from any accident previously evaluated.

. . 'O The proposed amendment will not involve any physical change in the margin of safety because there will be no physical change in the plant or change in operation of the plant. There may be some effect on the margin of safety in terms of the amount of review of operating characteristics and safety issues, but this change will_not be significant due to the independent assessment activities of recently created corporate level groups. These groups now have responsibilities that often overlap the technical specification responsibilities of the ONSG. When performing their onsite reviews, the ONSG will increase their use of corporate level independent review work performed by new departments.

Based on the preceding discussion, Commonwealth Edison believes this proposed amendment involves no significant hazards consideration.

4893K i

.